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Letter from the table · RC/TR/2026/T.35

The estimate is not the landed cost: a question about our strategy

A Trade Council member in Abu Dhabi asks the chair to make clear, itemised landed-cost estimates the first practical priority of the Small Importer Standard.

Dawit BekeleCo-author · Trade Council · United Arab EmiratesAbu Dhabi, United Arab Emirates
Trade30 March 2026Proposes amendment
3 pages · US Letter

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Trade Council

RC/TR/2026/T.35published

The estimate is not the landed cost: a question about our strategy

RC/TR/2026/T.35 · 30 March 2026 · Stance: Amend

Written originally in Arabic and English; translated by the Secretariat.

Letter from the table

To the Chair of the Trade Council,

I have a question about our strategy. When we say that small traders need better landed-cost transparency, what do we want a forwarder to do first: promise a final price, or give a small trader enough information to understand what is known, what is only estimated, and what may still change?

I ask because, in my experience, the problem is not always that a charge is improper. It is that I cannot plan around a number if I do not know what it includes.

On 12 February 2026, I requested an estimate for an import shipment. The commercial invoice was AED 18,400. Freight and insurance came to AED 2,100, making the customs value used in the clearance calculation AED 20,500. The estimate listed AED 1,020 for destination clearance and handling, but it did not make clear whether that amount covered every local service charge or only the items already known to the forwarder.

For this shipment, the customs entry showed AED 1,025 in customs duty and AED 1,076.25 in import VAT. Those figures matched a 5% customs-duty calculation on the stated customs value and 5% VAT on the value including that duty. I understand that UAE customs treatment can vary by goods, classification, exemptions and other circumstances; I am not presenting these figures as a rule for every import. The customs entry and tax record gave me a basis for checking the public charges. They did not answer what the estimate meant by “destination clearance and handling.”

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Trade CouncilRC/TR/2026/T.35 · Continued

On 25 February, the final account included a further AED 315 for storage and AED 85 for a document amendment. The total came to AED 24,021.25. I am not saying that either charge was necessarily wrong. I wanted to know when the storage period began, what event led to the amendment, and whether those costs could have been anticipated when I first asked for the estimate.

I tried to resolve it in ordinary ways. I compared the first estimate with the final account, checked the customs and VAT amounts against the clearance papers, and asked for the service charges to be separated from government charges. I also asked for a dated explanation of the storage and amendment items. I received documents, but I did not get one clear reconciliation that showed the starting estimate, each later addition, and the reason and date for each change. I recorded the dates and amounts in my Landed Cost Diary. That diary is useful to the Council only if the same fields can be compared across other traders’ experiences.

This is why I ask the chair about the order of our work. We are still gathering evidence. Should we begin by asking for a guarantee that is difficult to make when a shipment is inspected, reclassified, delayed or affected by information the forwarder does not yet have? Or should we first establish a minimum form of disclosure that makes estimates honest and usable?

My answer is to amend the proposal in that direction. The first requirement should be a written, itemised estimate that separates customs duty and taxes from the forwarder’s own fees and other third-party charges. It should state the assumptions used, identify which amounts are confirmed and which are provisional, and list common exclusions such as storage, inspection, amendment or extra handling where they may apply. If a cost changes, the trader should receive the amount, reason and date in a revised account. Where the reason is not yet known, the estimate should say so plainly rather than leave the small trader to discover the uncertainty at the end.

I would not ask the Council to insist that every shipment have one fixed final price before all facts are available. That may be unrealistic and could encourage a large contingency charge in every quote. Nor should the standard make a small trader responsible for interpreting customs classifications or tax treatment alone. The useful change is a common, plain-language way to show the calculation and the limits of the estimate. A trader could then

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Trade CouncilRC/TR/2026/T.35 · Continued

compare offers, set aside working capital, and ask a focused question before the goods are moving.

Could the chair make this the first test of our strategy: can a small importer read a quote and tell, without specialist help, what is included, what is not, and what event may add a cost? If we can collect cases against those questions, the Landed Cost Diary will help us distinguish a recurring gap in practice from a single difficult shipment. The Council can then decide whether the remedy needs a stronger duty to disclose, better guidance, or both.

I support the Small Importer Standard, but I ask the Council to amend its approach so that transparent estimates and itemised changes come first. That is a modest requirement. For a small trader, it can be the difference between making a decision with a number and making one with a guess.

Respectfully,

Dawit BekeleCo-author · Trade CouncilAbu Dhabi, United Arab Emirates

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Replies 7

Takeshi Miyazaki Osaka, Japan · 1 April 2026

I would choose a clear, itemised estimate over a promise of a final price. In Japan, import costs can depend on the product details and the paperwork, so a number without its assumptions can create false confidence. A forwarder can still be helpful by separating known transport and service fees from estimated duties and taxes, then saying what information is missing. I have found that even a modest range helps me plan better than a single figure that looks exact. The standard should make uncertainty understandable, not hide it.

Catherine Joy Dela Cruz Cebu, Philippines · 4 April 2026

I agree with the question: a final-price promise is not always realistic, but a trader deserves to know what the estimate includes. In the Philippines, I have been careful to ask whether local handling, brokerage and government charges are all in the quote. If those items are combined, I cannot tell whether a later difference came from a tax calculation or an added service fee. I would make itemisation the first practical priority and require the provider to mark each amount as fixed, estimated or still unknown. That seems fair to both sides.

Michael O'Connell Toronto, Canada · 6 April 2026

I would answer that the first goal should be an estimate a small trader can interrogate, not an unconditional final-price promise. In Toronto, I have seen import budgets become confusing when a quote mixes a provider's fee with taxes collected for government. Showing the basis for the customs value and the tax assumptions would make the number much more useful. I also think the estimate should explain what happens if the shipment is examined or the documents are incomplete. A transparent warning is better than discovering an unexplained charge at delivery.

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